Church of England

In the Church of England, both the Incumbent and the PCC are separate legal entities and will therefore be counted as separate Data Controllers under GDPR.

The ICO has confirmed to us that each Data Controller should have their own Privacy Notice/Policy, but that as some of the work is likely to be shared, some of the contents can be duplicated across both documents.

Existing Electoral Roll practice is compliant with the DPA and will be with the GDPR.

Since the Church Representation Rules, which govern practice in relation to the Electoral Roll and Annual Parochial Church meetings, are a Church of England Measure, they form part of the law of the land, and so the principal basis for the data processing is legal obligation not consent.

The objective of the Electoral Roll is to elect representatives to the PCC, and to vote at APCMs.  

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